Evergreen Your PHA:  Surprisingly Simple Solutions Exist

Facility siting in the United States is a requirement for PSM covered processes as stated in CFR 1910.119(e)(3)(v). However, OSHA’s interpretation of what is expected for “facility siting,” and whether that interpretation is reasonable as a matter of law, can be a difficult topic for owner/operators. Several industry generated guidance documents (e.g., API 752, CCPS) are typically used to provide the approaches to facility siting. While these documents provide a framework for facility siting, several details of these studies are left to the client to establish. OSHA does not regulate the guidance documents or officially review them but provides input via compliance citations. This paper discusses the selection of facility siting approaches and decisions facing plant operators conducting initial studies, revalidation of existing studies, and the legal requirements and implications of those decisions.